March/April 1995
A safety manual can be an integral part of your company’s overall risk management program. But how do you go about drafting one, and how do you ensure it’s effective? These tips from experienced recyclers can help you write the book on safety.
By Kent Kiser
Kent Kiser is an associate editor of Scrap Processing and Recycling
In 1991, George Ginsburg faced a challenge. His company, Jacobson Metal Co. (Chesapeake, Va.), had suffered several serious accidents during the year, including two deaths. To make matters worse, the firm had what's known in insurance lingo as a high experience modifier which was translating to steep workers' compensation premiums. "After all of this," says Ginsburg, the company's general manager, "we decided we had to do something about our safety. We decided that whatever it took to address the problem, it was going to be done."
Jacobson Metal isn't the first scrap recycling company to have this kind of safety revelation, and it certainly won't be the last. In these safety-conscious, regulation-heavy times, more and more scrap recyclers are taking whatever steps are available to improve their safety records, reduce their insurance costs, and insulate themselves from safety-related liability.
And one of the first steps many firms are taking in this effort is developing a safety manual that sets the basic parameters of their overall safety program. "A safety manual is a starting point," says Joe Natale, environmental/safety supervisor for Nirnco Shredding/Naporano Iron & Metal Co. (Newark, N.J.). "It's not the biggest part of a safety program, but it's an important part."
Why Do It?
Scrap recyclers aren't required by law or regulation to have a company-specific safety manual, but according to Dennis Caputo, vice president of environmental and safety compliance for Proler International Corp. (Houston), "It's just a good safety practice."
In general, a manual's purpose is to help a company implement an effective safety program and, hence, achieve the complementary goals of protecting employees from occupational injuries and reducing workers' comp premiums. "What you're ultimately trying to do with a safety program is reduce the number of accidents in order to bring your insurance premiums down," Natale says. "A manual is part of what you need to lower those costs."
A manual helps achieve this goal, in part, by forcing a company to clearly define and communicate its safety philosophy and procedures to both management and other staff, thus eliminating the arbitrary, unstructured nature of many companies' safety efforts. "Putting everything in black and white makes you consider which rules your company wants to abide by," says Bill Lowery, executive vice president of Annaco Inc. (Akron, Ohio). This is especially helpful in bringing unity and uniformity to a company's operations that are geographically spread out, as with Proler International, Caputo notes. "We wanted to get everyone consistent in their approach to safety from one facility to another," he says, "and the best way was to put together a manual that all facilities could refer to."
A safety manual can also improve employee morale by serving as a reflection of a company's management commitment to the physical welfare of its work force. "The whole safety attitude improves greatly when employees see management behind the issue," says Ginsburg. In addition, a manual can help "prevent or minimize future exposure to all manner of problems, such as employee health and injury claims, by anticipating and addressing potential employee hazards," notes Natale. Similarly, a manual, by establishing a company's commitment to overall safety, can help the firm fare better if it is subjected to safety-related inspections or investigations by the Occupational Safety and Health Administration (OSHA).
And there's yet another reason to have a safety manual, notes Michael Mattia, director of risk management for the Institute of Scrap Recycling Industries (ISRI) (Washington, D.C.). More and more, he observes, OSHA's standards offer general guidance rather than step-by-step instructions, leaving companies to figure out the best way to apply the standards in their particular operations. "OSHA may give you a performance standard, but you have to figure out how to apply or meet it," Mattia says. A safety manual, therefore, gives a company a formal opportunity to interpret and clarify OSHA safety standards as they should apply to its operations.
How to Do It
With reasons like that, there's no sense in putting off creating a safety manual for your recycling company. To make the going easier, some veterans from the safety manual trenches offer the following words of advice.
Don't Reinvent the Wheel. There's no reason to start from scratch if you don't have to. Perhaps your company has an old safety manual that can provide a framework from which to work. This was the case at Jacobson Metal, which combined aspects of its old safety manual with updated information to create its new manual.
Other recycling firms' safety manuals can also be a good starting point if your colleagues are willing to lend you such materials. "Don't be afraid to borrow from what other companies have done," says Natale. Other sources for sample safety manuals include insurance carriers and industry trade associations such as ISRI, which offers its Safety Reference Manual. (For ordering details, see "For More Information ..." on page 143.) Or maybe you can draw on the experience of employees who have worked for companies that had a safety manual.
An important point to remember here is not to adopt another source's safety manual verbatim, but rather adapt it to fit your company's particular needs and operations. ReMA's Safety Reference Manual, in fact, states specifically that it "is not designed to take the place of a company specific manual. Each company should develop a safety manual that pertains to company-specific policies and procedures, equipment, facilities, materials, and safety and human resources programs."
Size and Format. How many pages should your safety manual be? That depends on the publication's scope, the variety of your company's operations, and the detail incorporated in the book. In general, most seem to hover in the 30-to-50-page range, though Naporano's weighs in at more than 100 pages and Proler's fills most of a 3- inch-thick three-ring binder.
In terms of format, many safety manuals are published on normal 8 ½-x-11-inch paper and inserted into standard binders, but they are also often printed as pocket-size booklets measuring, say, 4 x 5 inches or 3 ½-x-6-inches. In addition to offering potential savings on printing and paper costs, this smaller format allows employees to easily carry the manual in a pocket to use as a quick reference on the job.
The Time Factor. As anyone who has implemented a safety program will tell you, every task in the process takes longer than you might expect-and creating a safety manual is no exception. "Don't underestimate how much time and effort it's going to take," Caputo advises.
While Jacobson Metal managed to create its manual in about three months, for instance, the majority of scrap companies take a year or more. Some attribute this considerable time investment to the extensive committee process involved in drafting their manual, while others say the time was necessary to ensure a comprehensive job was done.
Getting the Ball Rolling. "There's no one right or wrong approach to developing a safety manual," Caputo notes. Still, most recyclers stress, the effort has to begin with, and be wholeheartedly supported by, top management. "A manual itself is just a bunch of paper," Lowery notes, "but what it symbolizes is an agreement between a company's management and its employees that this is what the company is going to do regarding safety."
As a starting point, if your company doesn't already have a safety committee, it's a good idea to form one to orchestrate the project. Such committees are generally composed of a handful of company executives, managers, and operations supervisors.
Once your safety committee is established, you can get the process rolling, several recyclers suggest, by touring your plant(s), scrutinizing each operating area for safety concerns, and soliciting safety suggestions from employees and supervisors. "At our company, the responsibility for safety in each section was given to each supervisor, who talked with his employees and brought back a draft to our safety committee," says Lowery.
This bottom-up approach is essential, he explains, because "people are more likely to follow a rule or procedure that they've helped develop." Ginsburg can vouch for this, noting that the ideas for Jacobson Metal's manual "came from everyone here. Everyone played a part in the production of our manual." The company even held a contest challenging employees to come up with a motto to appear on the publication's cover to help garner employ employee support for the manual project. In the end, "Safety Is Our Habit" was the winning entry.
After supervisors submit their collected suggestions or a rough draft, the safety committee can then review and, if necessary, modify the information. And after organizing and refining the rules into final form, the manual should be ready to be printed. (While larger companies will likely have to produce their manuals using a commercial printer, smaller firms may be able to print and assemble theirs in-house.)
Building the Structure. In terms of how a manual should be organized and presented, most begin, logically enough, with an introduction, which can be a statement of the company's safety philosophy, a note from the president stating the manual's purpose, or something similar. Naporano's manual, for instance, opens with this statement:
The management of the company has moral and legal obligations to provide our employees with jobs and a workplace free of apparent hazards. Safety shall be considered as important as production, product quality, cost, and employee morale. It is essential that our safety program receive the continued support of all levels of management.
The company's safety program shall be a success through the active participation of all first-line supervisors and employees who are in the best positions to identify and make recommendations as to the correction of hazard.
Following the introduction, safety manuals are usually broken down into sections that cover general plant safety rules (Jacobson Metal's manual, for instance, lists 32) aswell as rules pertaining to safety equipment and clothing, traffic management, maintenance, housekeeping, ladders, hand tools, power hand tools, hazardous materials, winter hazards, and accident response.
Some manuals--such as Naporano's and Annaco's--are more detailed, covering rules for fire fighting equipment, scaffolding, lifting and handling, mobile equipment, loaders/tractors/forklifts, locomotives and railcars, welding and burning, general environmental controls, belt conveyors, cranes, boom signals, upstroke balers, guillotine shears, furnaces, metal identification and sorting, shredders, and confined spaces.
There are any number of ways to present your company's safety policies within these sections, but here's one simple format that works for some firms: Under each section topic heading, concisely state your company policy on the subject in an outline format. Note if this policy is based, in whole or in part, on federal or state laws or regulations, insurance requirements, and/or company-exclusive philosophy. Next, enumerate the safety procedures that must be followed to satisfy the company policy. These items, which are often listed in a bulleted format, can include administrative as well as operating procedures, and specifying protective equipment required and training needed.
As a capper, scrap plant safety manuals invariably end with a signature page that verifies--for obvious legal reasons--that an employee has received and reviewed the manual. "It's an acknowledgment in writing that the employee has, at the very least, read the portions in the manual that apply to his particular job and agrees to abide by them," says Caputo.
Keep it Simple. When it comes to writing your manual, most recyclers agree: Keep it short and simple. A 1993 University of California at Berkeley study indicated that nearly a third of U.S. adults read at or below the eighth-grade level, while the majority of reading materials used on typical jobs are written between the ninth-and twelfth-grade levels. On this point, Natal asserts, "You have to capture the entire audience, so your manual has to speak to the educational background of all employees."
In addition to writing your manual in short, simple sentences as much as possible, you will probably need to define terms that are technical or have the potential to be confusing. Natale also recommends using drawings or pictures to illustrate points and procedures covered in the manual.
And if your company has a multiethnic work force, it may be wise to print your manual in several languages to ensure that all employees get the necessary safety information. Naporano, for instance, offers its manual in English, Spanish, and Portuguese editions.
Be Realistic. In your endeavor to create a superior safety manual, don't be too idealistic in your goals. In other words, says Mattia, "Don't put something in writing that you are incapable of or don't plan on doing because it will come back to haunt you."
Instead, compare your manual "against what is actually happening in your operations," he says. "Don't create a document first, then try to shoehorn reality into it. The manual must work in practice, not just sound great on paper." The fear is that, if you have a safety requirement on the books and don't--or can't-abide by it, you could be leaving your company open to claims of negligence and willful violation, which could carry steep penalties.
Enforce It. After your safety manual is distributed, the main goals are to make sure it is, first, used and, second, enforced. "The important part is not simply having a safety manual but using it," Caputo says.
On the matter of enforcement, Lowery asserts, “It's like when you pass a law. The discipline must be there. That's usually the area where safety programs tend to break down. You have to be committed to enforcing the rules with anybody, including the company's executives." At Jacobson Metal, for instance, some employees who have broken the firm's safety code have been suspended a day or two without pay, Ginsburg notes, remarking, "Every one of our workers must agree to abide by the rules or possibly be terminated."
Keep It Current. A safety manual can only remain effective if it is periodically reviewed to ensure that it is up-to-date and still applicable to your changing operations.This doesn't have to mean a complete rewriting of the document. Instead, supplements or updates can be printed until the quantity of changes merits a total revamping.
Putting It in Writing
If you visit Jacobson Metal today, it's an entirely different company than it was just a few years ago, safety-wise. Since its 1991 safety lows, the firm's track record has "improved greatly," Ginsburg says, noting that its employees have currently gone close to 500 days without a lost-time injury. "We're starting to see some of the rewards from the programs we've implemented."
At the base of these programs is the company's safety manual. Although Ginsburg acknowledges that Jacobson Metal's safety manual "hasn't itself been a major motivating factor in the improvement of our safety," he and other recyclers who have created such manuals stress that they are a valuable part of their overall safety programs, one that helps give structure, momentum, and focus to the efforts that follow.
So, while a safety manual alone won't improve your company's safety record, it offers too many benefits to be overlooked. As Ginsburg remarks, "You don't realize a lot of things, you take them for granted, until you put them down in writing."
A safety manual can be an integral part of your company’s overall risk management program. But how do you go about drafting one, and how do you ensure it’s effective? These tips from experienced recyclers can help you write the book on safety.